ML25211A291
| ML25211A291 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 07/30/2025 |
| From: | Jeffery Lynch Kewaunee Solutions |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| KS-2025-014 | |
| Download: ML25211A291 (1) | |
Text
July 30, 2025 KS-2025-014 10 CFR 50.75(f)(1) 10 CFR 50.82(a)(8)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Kewaunee Power Station Facility Operating License No. DPR-43 NRC Docket Nos. 50-305 and 72-64
Subject:
Decommissioning Trust Fund Annual Report, Revision 1 On March 31, 2025, Kewaunee Solutions, Inc, (KS) submitted the annual status of decommissioning funding, status of funding for managing irradiated fuel, and financial assurance report for Kewaunee Power Station (KPS) as of December 31, 2024 (Reference 4).
Subsequently, an error was identified in the report. Section F, Current ISFSI Decommissioning Cost, states that The current site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $184.4M (2025 dollars, net current projections of DOE reimbursements). Section F was revised to say, decommissioning cost estimate is
$18.2M The References section of the report was updated to add the annual status report submitted on March 31, 2025, and the triennial ISFSI decommissioning funding plan submitted on May 22, 2025. There are no other changes in this revision.
Revision 1 of the report is attached. Revision 1 replaces Reference 4 in its entirety. The revised ISFSI decommissioning cost estimate does not change the conclusion that KPS has met the NRCs funding requirements and that no further action is currently required to demonstrate adequate funding assurance for decommissioning.
KS-2025-014 Page 2 This letter contains no new regulatory commitments. If you have any questions with respect to the contents of this letter, please contact me at 508-728-1421 or jrlynch@energysolutions.com.
Respectfully, Joseph R. Lynch Regulatory Affairs/Licensing Director (D&D)
EnergySolutions JRL/bed cc:
NRC Regional Administrator - Region III NRC Lead Inspector - Kewaunee Power Station NRC Project Manager - Kewaunee Power Station
- Kewaunee Power Station Annual Decommissioning Fund Status and Financial Assurance Report as of December 31, 2024 - Revision 1 Joseph R. Lynch Digitally signed by Joseph R.
Lynch Date: 2025.07.30 14:38:28 -04'00' Kewaunee Power Station Annual Decommissioning Fund Status and Financial Assurance Report As of December 31, 2024 Page 1 of 3 As required by 10 CFR 50.75(f), and 50.82(a)(8), Kewaunee Solutions, Inc. (KS) reports the following information for Kewaunee Power Station (KPS):
A. Formula Cost Amount per 10 CFR 50.75(c)
KS does not use the calculation in 10 CFR 50.75(c) for any decommissioning cost estimates or evaluations.
B. Current Decommissioning Cost Estimate The required minimum funding assurance amount for KPS, as of December 31, 2024, is based on the site-specific Decommissioning Cost Estimate (DCE) developed in accordance with 10 CFR 50.82(a) and included in the Post-Shutdown Decommissioning Activities Report (PSDAR) Revision 2 (Reference 1).
Additional reporting requirements are documented on Table 1 of this Enclosure. Table 1 provides the KS revised total estimate information as required by 10 CFR 50.82. The revised total cost estimate to complete decommissioning for the KPS site is $1,080.1M (in 2025 dollars, net of Department of Energy (DOE) reimbursements) as shown in Tables 1 and 2 and as described below. Of that total cost estimate, the revised estimate includes the following expenses:
- $854.0M for license termination (the cumulative decommissioning expenditures in the amount of 330.0M and the remaining decommissioning estimated cost of 524.0M). The remaining decommissioning estimated cost of $524.0M was a product of inflation to 2025 dollars, supply chain impacts, procurement cost increases, and actual contract costs versus original estimates in the PSDAR.
- $184.4M for spent fuel management (the cumulative decommissioning expenditures in the amount of 30.1M and the remaining decommissioning estimated cost of 154.3M)
- $41.6M for the decommissioning cost estimate for site restoration (the cumulative decommissioning expenditures in the amount of 7.1M and the remaining decommissioning estimated cost of 34.5M)
C. Current Decommissioning Fund Balance The KPS Decommissioning Trust Fund (DTF) balance as of December 31, 2024, was
$752.4M. This amount represents the market value of the DTF fund, net of any material current income tax liability on realized gains, interest, dividends, and other income of the trust. The trust fund amount is the total available for decommissioning including costs of license termination, spent fuel management, and site restoration activities. Note that KS received exemptions from 10 CFR 50.82(a)(8)(i)(A) to allow the KPS DTF to be used for Kewaunee Power Station Annual Decommissioning Fund Status and Financial Assurance Report As of December 31, 2024 Page 2 of 3 site irradiated fuel management and site restoration costs (References 2 and 3, respectively).
D. Assumptions Used Regarding Rates of Escalation for Decommissioning Costs, Earnings on Funds, and Other Factors Used in Funding Projections KS has assumed a 2% real rate of return as allowed by 10 CFR 50.75(e)(1)(i).
E. Rates used to Inflate Decommissioning Costs The estimates in the 2021 KPS Revised PSDAR (Reference 1) were provided in 2021 dollars. The estimates provided in Table 1 of this Enclosure have been inflated to 2025 dollars. The Bureau of Labor Statistics (BLS) data provided the basis for the decommissioning cost estimate inflation rate forecast. Decommissioning costs are inflated using a weighted average of BLS indices for Labor, Energy, Consumer Price Index, Materials, and Equipment. For burial inflation factor, KS utilized NUREG-1307, Report on Waste Burial Charges: Changes in Decommissioning Waste Disposal Costs at Low-Level Waste Burial Facilities, Revision 20. KS has used a factor of 1.02125 to calculate the inflation to 2025 dollars.
F. Current ISFSI Decommissioning Cost The current site-specific Independent Spent Fuel Storage Installation (ISFSI) decommissioning cost estimate is $18.2M (2025 dollars, net current projections of DOE reimbursements). The ISFSI estimated costs are based on the estimated costs provided in Reference 5.
G. Decommissioning Financial Assurance Financial assurance for decommissioning is provided by the prepayment method, coupled with an external trust fund, in accordance with 10 CFR 50.75(e)(1)(i) and 10 CFR 72.30(e)(1) as approved by NRC in their approval of the license transfer to KS.
H. Changes in the Decommissioning Funding Plan Trust Agreement There are no changes to the Decommissioning Funding Plan Trust Agreement.
Refer to Tables 1 and 2 of this Enclosure for additional required reporting data. Table 2 provides a cash flow analysis using the revised decommissioning cost estimates developed by KS. This cash flow analysis demonstrates that the KPS decommissioning trust fund is sufficiently funded to cover costs as estimated for the license termination, spent fuel management and site restoration activities necessary to complete safe and compliant decommissioning of the site.
Kewaunee Power Station Annual Decommissioning Fund Status and Financial Assurance Report As of December 31, 2024 Page 3 of 3 References
- 1. Letter ES-2021-002 from Gerard van Noordennen, EnergySolutions to Document Control Desk, USNRC, Notification of Amended Post-Shutdown Decommissioning Activities Report (Revision 2) for Kewaunee Power Station, dated May 13, 2021 (ML21145A083)
- 2. Letter from Christopher Gratton, USNRC, to David A. Heacock, Dominion Energy Kewaunee, Inc, Kewaunee Power Station - Exemptions from the Requirements of 10 CFR Part 50, Section 50.82(a)(8)(i)(A) and Section 50.75(h)(1)(iv) (TAC No. MF1438),
dated May 21, 2014 (ML13337A287)
- 3. Letter from Karl Sturzebecher, USNRC, to Amy C. Hazelhoff, EnergySolutions, Kewaunee Power Station - Exemption to Allow Use of Funds from the Nuclear Decommissioning Trust for Site Restoration and to Remove a Notification Requirement for the Disbursal of Funds from the Decommissioning Trust (EPID No. L-2023-LLE-0008), dated January 26, 2024 (ML23339A133)
- 4. Letter KS-2025-005 from Joseph R. Lynch, EnergySolutions to U.S. Nuclear Regulatory Commission, Decommissioning Trust Fund Annual Report, dated March 31, 2025 (ML25090A215)
- 5. Letter KS-2025-010 from Joseph R. Lynch, EnergySolutions to U.S. Nuclear Regulatory Commission, ISFSI 10 CFR 72.30 Decommissioning Funding Plan, dated May 22, 2025 (ML25142A085)
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Page 1 of 1 1 NDT earnings reflect an assumed 2% Real Rate of Return (RRR) Net of Taxes on realized gains 2 2025 Beginning of Year NDT Balance is net of realized tax liabilities 3 Columns may not add due to rounding 4 Withdrawals includes estimated payments for taxes on unrealized gains and any estimated deposits into the NDT fund 5 Spent Fuel Management Costs from 2045 to 2055 are, in part, reflective of DOE reimbursements. The negative years include DOE reimbursements in excess of spend due to timing of reimbursements.